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        T R O U B L E D   C O M P A N Y   R E P O R T E R

                           E U R O P E

           Tuesday, November 27, 2018, Vol. 19, No. 235


                            Headlines


F R A N C E

ACROPOLE BIDCO: Fitch Assigns B LT IDR, Outlook Stable
PARTS HOLDING: Moody's Downgrades CFR to B3, Outlook Stable
RAMSAY GENERALE: Moody's Affirms Ba3 CFR; Outlook Stable


G E O R G I A

GEORGIAN RAILWAY: Fitch Affirms B+ LT IDR, Alters Outlook to Pos.


I R E L A N D

ARMADA EURO III: Moody's Assigns (P)B2 Rating to Class F Notes
ARROW CMBS 2018: Fitch Assigns B-sf Rating to Class F Notes
GRIFFITH PARK: Moody's Assigns B2 Rating to Class E-R Notes


I T A L Y

ITALY: Rising Bond Yields to Threaten Stability of Banks
PIAGGIO AEROSPACE: Italian Government Aims to Protects Jobs


P O L A N D

GETIN NOBLE: Fitch Puts B- IDR on Rating Watch Negative
IDEON SA: Opts to Continue Restructuring Process


R U S S I A

EVRAZ GROUP: Moody's Upgrades CFR to Ba1, Outlook Stable
GAZPROMBANK JSC: Fitch Affirms BB+ Long-Term IDR, Outlook Pos.


S P A I N

DISTRIBUIDORA INTERNACIONAL: Moody's Cuts CFR to B2, Outlook Neg.


U N I T E D   K I N G D O M

FOLGATE INSURANCE: A.M. Best Assigns B(Fair) FSR, Outlook Stable
FONTWELL SECURITIES 2016: Fitch Affirms CCCsf Class S Debt Rating
INTERSERVE PLC: Expects Higher Than Expected Debt This Year
JOHNSON PRESS: Moody's Lowers CFR to Ca, Outlook Stable
NEW LOOK: Moody's Lowers CFR to Ca, Outlook Negative

PHONES4U: Taps Insolvency Expert to Assess Damages Claims
VICTORIA PLC: Fitch Withdraws BB-(EXP) LT Issuer Default Rating

* UK: 1,267 Retail Stores Earmarked for Closure Since January


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F R A N C E
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ACROPOLE BIDCO: Fitch Assigns B LT IDR, Outlook Stable
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Fitch Ratings has assigned Acropole BidCo SAS (Acropole BidCo) a
final Long-Term Issuer Default Rating (IDR) of 'B' with Stable
Outlook. It has also assigned Sisaho International's senior
secured facilities a final 'B+' rating with a Recovery Rating of
'RR3' (55%). The rated companies are the entities incorporated by
private equity sponsor Charterhouse for the acquisition of SIACI
Saint Honore SAS.

SIACI Saint Honore is the number 2 French-based B2B insurance
broker for corporates and is focused on three main areas: French
employee benefits, international private medical insurance and
French domestic P&C and speciality brokering. All services are
targeted at large enterprise corporate clientele. SIACI Saint
Honore also has B2B exposure to French-speaking Switzerland and
fast-growing African markets via strategic associate operations,
while relevant entities are also present in Middle East and Asia.

The issuance and syndication of a EUR485 million term loan B
(TLB), including a EUR80 million revolving credit facility (RCF)
has been completed at the beginning of November. In comparison
with the initial draft terms, the final documentation comprises a
475bp margin for the TLB (initially assumed at 375bp), an
increase in the guarantors' coverage test from 75% to 80% and
stricter limitations on permitted payments and baskets. The terms
of the RCF remain unchanged.

1H18 trading showed softer revenue for P&C, partially compensated
by the performance of International Mobility. As a consequence
LTM EBITDA was slightly below management's expectations in
absolute terms, in spite of strong cost management. Fitch has
partially adjusted its forecasts but believes that projected
credit metrics remain consistent with a 'B' rating and a Stable
Outlook.

KEY RATING DRIVERS

French Brokerage Market Stable: Insurance broker activity in
France over the past decade has shown moderate growth between
international and national mid-cap players. The expected growth
of insurance premium and brokerage fees, linked to GDP and to
structural changes on health and pensions, indicates potential
growth of about 3% for health and pensions and below 2% for P&C.
The regulatory environment is neutral to positive, with potential
upside from ongoing legislative changes.

Digital Evolution Presents Challenges: The insurance sector is
facing a digital evolution in both its proposition to customers
and internal efficiency. Digital levers enable reduction of
operating costs in people-intensive areas, paving the way for
further operational efficiencies and allowing mid-size players to
efficiently address smaller clients. On the other hand, digital
helps promote disruptive business models via "insurtech"
approaches, challenging traditional players mainly in B2C and
small business segments. B2B platforms such as SIACI Saint Honore
remain more protected over the medium term, due to the higher
complexity of their products and customers' requirements.

Acquisition Strategy Delivery Key for Growth: Anaemic economic
growth, together with regulatory and digital developments,
pressures small players and stimulates M&A interest from middle
and large brokers, such as SIACI Saint Honore, in specialised
niche operators. Fitch understands from management that M&A
undertaken by SIACI Saint Honore under the previous shareholder's
(Ardian) ownership contributed to above-trend growth and
operating profit expansion. Successful integration of the
company's limited number of small acquisitions every year is key
to further market share gains and margin expansion. Execution
risk is mitigated by the expected small number and limited size
of targeted add-ons.

Cash Conversion Shows Positive Trend: The combination of high
margins and neutral cash impact from working capital contribute
to a cash-generative profile. Cash conversion is expected to
improve after the end of SIACI Saint Honore's extraordinary capex
plan expected for 2019. Fitch forecasts investments in digital
and transformational projects at slightly higher levels than
management's indications. Under its rating case successful
implementation of SIACI Saint Honore's M&A strategy will boost
free cash flow (FCF) margin to 8.2% in 2020 from 5.8% in 2018.
This supports a gross deleveraging path and current rating
headroom should the acquired entities require unexpectedly higher
capex or if integrations fail to deliver desired cost savings or
pricing power.

High Leverage, Moderate Deleveraging Potential: Fitch estimates
SIACI Saint Honore's gross leverage post completion of the
acquisition by Charterhouse to be around 7.0x on an adjusted
funds from operations (FFO) basis, which is high relative to
multinational competitors' but broadly in line with B category
peers' such as Ardonagh Group (B/Negative) in the UK. Under its
rating case, the acquisition strategy will result in draw-downs
of the RCF but below the trigger of the springing covenant. The
FCF-accretive nature of the acquisition plan should allow
moderate deleveraging to 6.5x in 2020 from 7.0x in 2018. Failure
to implement the acquisition strategy would likely jeopardise the
deleveraging potential.

DERIVATION SUMMARY

SIACI Saint Honore's size is significantly smaller than that of
publicly traded global peers such as Aon, Marsh & McLennan and
Willis Towers Watson, which are all investment-grade issuers. The
company is mainly concentrated on the French market and has a
less diversified product offering than multinational players. In
comparison with 'B' category national players such as Ardonagh
Midco 3 plc (B/Negative), SIACI Saint Honore is slightly smaller
but has lower business risk due to its focus on the corporate
sector, and lower execution risk stemming from an acquisition
strategy focused on smaller niche targets.

KEY ASSUMPTIONS

Fitch's Key Assumptions within its Rating Case for the Issuer

  - Like-for-like sales growth at 8% CAGR for 2017-2021

  - EBITDA margin growth of about 1.8% p.a. by 2021

  - Total capex (including for acquired targets) of EUR105
million for 2018-2021

  - Acquisitions generate in excess of EUR15 million EBITDA
equivalent to 2021

  - Call option on African operations exercised in 2021

  - EUR23 million of yearly drawdown under the RCF for 2019-2021

Key Recovery Assumptions

As the majority of the value of the business lies in the brand
and client portfolio, Fitch has applied the going concern
approach in its recovery analysis.

Fitch applied a 15% discount to its EUR74 million EBITDA based on
the expected LTM figure for September 2018 before the pro-forma
effect of the acquisitions. This level of discount reflects a
disruptive change from regulations or a severe reputational hit
to the company leading to a large loss in clients. The level of
discount is in line with UK peer Ardonagh Group.

Fitch applied a 5.5x multiple to reflect SIACI Saint Honore's
leading position in the French corporate broking market and
strong FCF generation. The multiple is supported by median EBITDA
multiples of around 10x for public peers, such as Aon, Marsh &
McLennan and Willis Towers Watson. This figure is also in line
with Ardonagh Group's.

SIACI Saint Honore's RCF is assumed to be fully drawn upon
default. The RCF ranks pari passu with SIACI Saint Honore's
senior secured TLB. Therefore following a strict debt waterfall,
Fitch assesses recoveries for senior secured creditors at 55%,
resulting in an instrument rating of 'B+'/'RR3'.

RATING SENSITIVITIES

Developments That May, Individually or Collectively, Lead to
Positive Rating Action

  - FFO adjusted gross leverage below 5.5x

  - FFO fixed charge coverage above 2.5x

  - EBITDA margin equal to or greater than 25%

  - Successful M&A delivering higher FCF margin and synergies

Developments That May, Individually or Collectively, Lead to
Negative Rating Action

  - FFO adjusted gross leverage above 7.0x

  - FFO fixed charge coverage below 2.0x

  - EBITDA margin below 20%

  - Unsuccessful M&A with dilutive effect on FCF

  - Departure from announced target selection criteria such as
acquisition of a bigger player

LIQUIDITY

The buyout by Charterhouse was financed by a combination of
equity and a covenant-lite EUR485 million senior secured TLB
including a EUR80 million RCF for permitted acquisitions. Fitch
assesses liquidity as satisfactory due to positive cash
conversion and the available RCF.


PARTS HOLDING: Moody's Downgrades CFR to B3, Outlook Stable
-----------------------------------------------------------
Moody's Investors Service (Moody's) has downgraded car parts
distributor Parts Holding Europe S.A.S' corporate family rating
to B3 from B2 and probability of default rating (PDR) to B3-PD
from B2-PD.

Concurrently, Moody's has downgraded to B3 from B2 the ratings on
the senior secured fixed and floating notes due 2022 issued by
Autodis S.A.

The rating outlook is stable.

"The downgrade of Parts Holding Europe's ratings reflects the
material increase in the company's Moody's-adjusted leverage to
8.0x from 7.0x following the debt-funded acquisition of Oscaro,
the leading online car parts retailer in France", says Eric Kang,
Moody's lead analyst for Parts Holding Europe. "Procurement
synergies and initiatives to optimise Oscaro's cost base could
support deleveraging towards 6.5x in the next 18 months but there
is execution risk related to the integration of Oscaro, and
further debt-funded acquisitions could hinder the pace of
deleveraging".

RATINGS RATIONALE

Parts Holding Europe's B3 CFR with a stable outlook reflects its
high leverage following the acquisition of Oscaro. Moody's
estimates that the company's Moody's-adjusted debt/EBITDA will
increase to 8.0x from 7.0x (as of September 2018, excluding
future cost savings and synergies) because the transaction will
be funded with drawings under the revolving credit facility. The
acquisition will also have an initial dilutive impact on the
company's margins because Oscaro had a negative EBITDA of
approximately EUR9 million in the last twelve month ended
September 30, 2018.

The initial weakening of Parts Holding Europe's credit metrics
offsets the benefits of the acquisition to its business profile.
Oscaro is the leading online car parts retailer in France with a
market share of around 50%, 2.5x the size of its nearest
competitor according to the company. Parts Holding Europe also
expects the market to grow at 4%-5% p.a. on average until 2022
driven by continuation of the growth of the e-commerce channel
within the overall retail sector. In contrast, the company's
expects the growth for Autodis' core business-to-business
distribution markets in France to average 1.6% p.a. until 2022.

In Moody's view, the acquisition, which constitutes Parts Holding
Europe's largest acquisition to date in terms of revenue, entails
higher degree of execution risk compared to the company's past
acquisitions. Although the company has a good track record in
generating purchasing synergies from past acquisitions, the
rating agency cautions that the successful integration of Oscaro
will also require the implementation of a number of initiatives
to improve commercial operations, the cost base, and the supply
chain.

Moody's expects modest organic growth, merger synergies, and cost
efficiencies will lead to a reduction of the Moody's-adjusted
debt/EBITDA towards 6.5x within 18 months but with execution
risks as discussed. Additionally, the pace of deleveraging could
be hindered by further debt-funded acquisitions.

More positively, the rating also incorporates the company's (1)
leading market position in the resilient but fragmented and
competitive French independent automotive aftermarket industry,
(2) strong integrated distribution network and recognised brand
covering all areas in France, (3) fragmented and loyal customer
base, and (4) good track record in extracting purchase synergies
from acquired businesses.

LIQUIDITY

Liquidity is weakened due to the use of the now fully drawn EUR90
million revolving credit facility (RCF) to fund the acquisition
of Oscaro but remains adequate reflecting Moody's expectation of
modest positive free cash flow generation in the next 12 to 18
months, closing cash of approximately EUR66 million, as well as
access to factoring facilities of EUR190 million in aggregate
(on- and off-balance sheet) with an average utilisation of EUR60
million throughout the year.

Whilst the RCF will be fully drawn following the acquisition of
Oscaro, Moody's expects the company to refinance drawings with
longer term debt in the near term. The RCF benefits from a
springing financial maintenance covenant, set at 0.7x super
senior net leverage when the RCF is drawn. A breach of this
maintenance covenant triggers a draw-stop, but not an event of
default.

STRUCTURAL CONSIDERATIONS

The B3 rating on the senior secured notes, at the same level as
the CFR, reflects their subordination to the relatively small
super senior RCF ranking ahead as well as trade payables at
operating subsidiaries mitigating the senior secured notes
relatively weak guarantor and security packages. While the RCF
benefits from the same security package as the notes, it will
rank ahead of the notes in an enforcement scenario under the
provisions of the intercreditor agreement. Also, the obligations
of the notes' subsidiary guarantor are capped at EUR200 million.

RATING OUTLOOK

The stable outlook reflects Moody's expectations that modest
organic growth, merger synergies, and cost efficiencies will lead
to a reduction of the Moody's-adjusted debt/EBITDA towards 6.5x
within 18 months, albeit with execution risk.

FACTORS THAT COULD LEAD TO AN UPGRADE/DOWNGRADE

While unlikely in the near term given the rating action, Moody's
will consider upgrading the ratings if growth in earnings and a
more conservative financial policy would result in a Moody's-
adjusted debt/EBITDA of below 6.5x on a sustained basis as well
as the maintenance of adequate liquidity including positive free
cash flow.

Moody's will consider downgrading the ratings if the Moody's-
adjusted debt/EBITDA remains above 7.5x on a sustained basis, or
liquidity weakens including negative free cash flow.

PRINCIPAL METHODOLOGY

The principal methodology used in these ratings was Distribution
& Supply Chain Services Industry published in June 2018.

COMPANY PROFILE

Headquartered in France, Parts Holding Europe is the holding
company of Autodis, a leading aftermarket light vehicle spare
parts distributor and truck spare parts distributor and repairer
in France, Benelux and Italy. The company is owned by Bain
Capital and reported revenue of approximately EUR1.3 billion in
2017.


RAMSAY GENERALE: Moody's Affirms Ba3 CFR; Outlook Stable
--------------------------------------------------------
Moody's Investors Service has affirmed the Ba3 corporate family
rating and Ba3-PD probability of default rating of Ramsay
Generale de Sante following the acquisition of Capio AB.
Concurrently, the rating agency has assigned a Ba3 rating to the
EUR1,015 million worth of senior secured credit facilities and
has assigned a Ba3 rating to the incremental EUR750 million worth
of senior secured term loan. The outlook on all ratings has been
changed to stable from positive.

On November 7, 2018, RGdS finalised its public cash offer for
Capio after receiving approval from 98.51% of its shareholders.
The transaction is financed with a EUR550 million worth of
subordinated bonds and the new EUR750 million senior secured term
loan facility. The EUR550 million subordinated bonds is
subscribed by RGdS's two controlling shareholders namely Ramsay
Healthcare (UK) and Predica and will be entirely refinanced with
a capital increase with preferential subscription rights for the
shareholders in RGdS within six months from the acquisition.

RATINGS RATIONALE

The affirmation of the CFR reflects the following drivers:

  -- the acquisition will increase RGDS's diversification across
Europe thanks to Capio's leading market shares in the Nordics and
its operations in Germany;

  -- the acquisition will further increase RGdS's leading
position in the French private hospital sector, where Capio
achieved EUR538 million in revenues in the 12 months ended June
30, 2018 compared to EUR 2,217.3 million for RGDS in France over
the same period, widening the gap with its main competitor Elsan
SAS (B1, stable);

  -- the execution risk related to the integration of Capio's
business, in particular in the Nordics and in Germany, where RGdS
does not operate. This risk is partially mitigated by RGdS's
successful track record of acquiring and integrating hospitals in
France, the long track record of Capio in the Nordics as one of
the leading private hospital groups in the region and
decentralized organization whereby local management teams will
oversee the operations thus minimizing risks of a cultural clash;

  -- the ongoing commitment from the controlling shareholders,
Ramsay Healthcare and Predica, to maintain a balanced leverage
profile as evidenced by the EUR550 million minimum equity funding
of Capio's acquisition;

  -- at the same time, RGdS's leverage, as measured by Moody's-
adjusted (gross) debt/EBITDA, pro-forma of the acquisition of
Capio and including the synergies planned for the year ending
June 2019, will increase to 5.1x from 4.9x as of June 2018, which
is outside of the parameters Moody's has set for the Ba3 rating.
This reflects expected EBITDA contribution of Capio and the
financing mix with EUR 550 million equity and EUR750 million
incremental credit facility. Moody's believes that the leverage
ratio will reduce below 5.0x in the next 24 months on the back of
modest organic earnings growth rates and synergies associated
with the Capio acquisition.

The Ba3 CFR continues to reflect (1) RGdS's large scale and
leading positioning within the market for French private hospital
providers; (2) the company's industrial ownership through Ramsay
Health Care; (3) its overall good degree of visibility in terms
of future operating performance; (4) its favourable demographics,
which should continue to drive volume growth and thereby mitigate
some of the expected pressure from tariff reductions, allowing
continued solid adjusted EBITDA margin of around 17% pro-forma of
the Capio acquisition; and (5) the overall high barriers to entry
resulting from the need to obtain necessary authorisations and
attract qualified personnel.

These factors are balanced to an extent by (1) RGdS's fairly high
leverage which Moody's estimates at 5.1x as of the end of June
2019 and pro-forma of the Capio acquisition; (2) Moody's
expectation of continued pressure on tariffs in France, which, in
view of the company's largely fixed-cost structure, may constrain
the prospects of profitability improvement and further
deleveraging; and (3) a certain degree of event risk because RGdS
is expected to continue to have an active role in the
consolidation of the European private hospital market.

Moody's expects RGdS to maintain a good liquidity profile over
the next 12 months. Pro-forma of the acquisition of Capio, RGdS
has a cash balance of around EUR350 million. The company's
liquidity profile is further supported by Moody's expectation of
a positive, albeit modest, free cash flow, as well as RGdS's
access to a fully undrawn EUR100 million revolving credit
facility (RCF) and EUR35 million available under the EUR75
million capital spending/acquisition facility. These liquidity
sources will cover RGdS's needs over the next 18 months including
EUR64 million in short-term debt as of the end of June 2018.The
next large debt maturities will occur in 2022 when the EUR 840
million term loan is due.

In addition, Moody's expects the company to maintain ample
capacity against the springing net leverage covenant included in
the RCF and set at 5.0x (4.3x pro forma of the Capio
acquisition), which is triggered only when the EUR100 million RCF
is drawn by more than 40%. Moody's also expects RGdS to maintain
satisfactory capacity against its leverage ratio test for debt-
financed acquisitions set at 4.5x for acquisitions larger than
EUR 30 million.

STRUCTURAL CONSIDERATIONS

The Ba3 rating assigned to the EUR1,590 million worth of senior
secured term loan (EUR840 million prior to the fully underwritten
incremental term loan facility), the EUR100 million worth of RCF
and the EUR75 million worth of capital spending/acquisition
facility, reflects their pari passu ranking in the capital
structure and the upstream guarantees from material subsidiaries
of the group. They are secured by collateral essentially
consisting of share pledges. In addition, the capital structure
includes around EUR180 million of finance leases and a EUR118
million loan backed by a pledge of the securities of one of
RGdS's real estate subsidiaries. The Ba3-PD probability of
default reflects Moody's assumption of a 50% family recovery
rate, typical for bank debt structures with a limited or loose
set of financial covenants.

RATING OUTLOOK

The outlook on the rating is stable and reflects Moody's
expectations that RGdS will gradually deleverage its balance
sheet bringing Moody's-adjusted debt/EBITDA ratio below 5.0x and
towards 4.5x over time. While bolt-on acquisitions can be
accommodated, the current rating does not leave flexibility for
larger debt-financed acquisitions.

WHAT COULD CHANGE THE RATING UP/DOWN

Positive pressure on the rating could develop if RGdS' operating
performance continues to improve, allowing the company's
leverage -- measured by debt/EBITDA (Moody's-adjusted) -- to go
below 4.5x on a sustained basis, while it maintains a robust
positive free cash flow.

Negative pressure could develop if RGdS' Moody's-adjusted
leverage increases sustainably above 5.0x or if the company's
liquidity weakens.

PRINCIPAL METHODOLOGY

The principal methodology used in these ratings was Business and
Consumer Service Industry published in October 2016.

With total revenue of EUR2.5 billion for the fiscal year ended
June 30, 2018, RGdS is the largest private hospital operator in
France. Before the acquisition of Capio. the company operated 121
private clinics and offered a wide range of medical services,
with around 80% of its revenue coming from medicine, surgery and
obstetrics.

Capio is a leading, pan-European healthcare provider offering a
broad range of medical, surgical and psychiatric healthcare
services through its hospitals, specialist clinics and primary
care units. Based in Sweden, Capio operates in five countries;
Sweden, Norway, Denmark, France and Germany. During the last
twelve month period ending Jun-2018, Capio generated SEK 15,867m
(EUR1,6 billion equivalent) of sales.

Majority of RGdS is owned by Ramsay Health Care (UK) Limited
(51%) and Predica (38%).


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GEORGIAN RAILWAY: Fitch Affirms B+ LT IDR, Alters Outlook to Pos.
-----------------------------------------------------------------
Fitch Ratings has revised JSC Georgian Railway's (GR) Outlook to
Positive from Stable while affirming the entity's Long-Term
Foreign and Local Currency Issuer Default Ratings (IDRs) at 'B+'.
GR's senior unsecured debt ratings have been also affirmed at
'B+'.

The revision of the Outlook to Positive reflects the recent
similar change on the Georgian sovereign (BB-/Positive). The
ratings reflect its assessment of GR's standalone credit profile
(SCP), which combined with Fitch's application of a top-down
approach under its Government-Related Entities (GRE) Criteria,
leads to one-notch differential of the company's ratings with
Georgia.

KEY RATING DRIVERS

Status, Ownership and Control (Strong)

GR is a national integrated railway transportation monopoly,
which is indirectly 100%-owned by Georgia via national key asset
manager -- JSC Partnership Fund (PF, BB-/Positive). The company
is a rare combination of monopoly and deregulated tariff-setting.

The state exercises adequate control and oversight over GR's
activities both directly and via PF, including approval of the
railway company's budgets and investments. PF acts as an arm of
the state, by approving GR's major transactions (procurement,
borrowings, significant non-financial obligations, etc.). GR's
nine-member supervisory board is nominated and controlled by the
government, while goods and services are tendered in accordance
with the law on public procurement.

Fitch does not expect changes to GR's legal status in the medium
term. The government has plans to privatise 25% of the company,
and while the exact timing is not yet defined, it should be
neutral for GR's link with the state. GR is also obliged under
the EU-Georgia Association Agreement to implement EU directives
on railway transport, which require the infrastructure segment to
be segregated by 2022. Fitch expects that by this deadline GR
will have separate entities for different business segments under
a single holding structure, albeit with immaterial effect to its
monopolistic position.

Support Track Record and Expectations (Moderate)

GR receives mostly non-cash and indirect state support.
Historically, support of GR's long-term development has been via
state policy incentives and asset allocations. In 2012-2016 state
capital injections totalled GEL53 million, comprising mostly
infrastructural assets, such as land plots, transmission lines
and substations. In addition, strategic infrastructure, such as
railroads and transmission lines, is exempt from property tax in
Georgia.

GR enjoys greater pricing power than its regional peers rated by
Fitch - JSC Russian Railways (BBB-/Positive), JSC National
Company Kazakhstan Temir Zholy (BBB-/Stable) and PJSC Ukrainian
Railway (B-/Stable). GR's tariffs are fully deregulated, allowing
tariffs in both freight and passenger segments to be swiftly
adjusted to market conditions. Freight tariffs are set in US
dollars, resulting in natural hedge for a company that operates
in a country with a dollarised economic environment. This is a
departure from the national pricing regime, which requires
pricing of goods and services to be set in Georgian lari.

Such policy measures partly offset weak direct support from the
state. Unlike most regional peers GR does not receive any
subsidies for the loss-making passenger business. This segment
comprises only 5% of total revenue and continues to be cross-
subsidised by the freight transportation segment.

Socio-Political Implications of Default (Moderate)

GR plays a critical role in tapping Georgia's transit potential,
future development and in maintaining economic relations with
neighbouring countries. The company holds around a 30% share of
total freight transportation in the country and a dominant
position in transit trade flows.

GR's rail network, in association with Azerbaijan Railway, forms
a key segment of the Transport Corridor Europe Caucasus Asia.
GR's revenue constituted 1.2% of Georgia's GDP in 2017, and the
company accounted for around 5% of the country's services export.
The company is among the largest taxpayers and employers in
Georgia.

In its view, a default of GR may lead to some service
disruptions, but not of irreparable nature, and may not
necessarily lead to significant political and social
repercussions for the national government. In this case company's
hard assets will still be operational and alternative modes of
transportation remain available. It would instead hamper the
capital modernisation programme of the company and long-term
prospects of Georgia's economy.

Financial Implications of Default (Strong)

GR is a large external borrower in Georgia's context with a 29%
share in Eurobond issues, acting as a quasi-funding vehicle for
government investments. As of end-September 2018, Georgian GREs
accounted for USD1.3 billion, or about 76% of the total Eurobonds
of Georgian issuers. A default by GR could significantly impair
the borrowing capacity of the government and other GREs due to
Georgia's reliance on external financing and the small size of
the domestic economy.

Its assessment of GR under the GRE criteria results in a final
score of 22.5 points and in conjunction with the company's SCP
assessment at 'B(cat)' leads to GR's rating being notched down
once from the sovereign's IDR of 'BB-'(Positive).

Standalone Rating Assessment

GR's 'B(cat)' SCP factors in its assessment of weaker revenue
defensibility, midrange operating risk and weaker financial
profile. SCP is supported by the company's monopolistic position
combined with a deregulated tariff system and by the projected
stabilisation of the company's financial profile.

Fitch projects gradual stabilisation of GR's operating
performance and cash generation in 2018-2022. Fitch forecasts
zero growth in revenue in 2018, followed by a 3.5% yoy increase
in 2019 and a 4.5% yoy increase in 2020-2022, which compares
favourably with a negative trend in 2015-2017. Fitch estimates
Fitch-calculated EBITDA of GEL170 million in 2018 and GEL220
million-GEL240 million by 2022.

At the same time Fitch expects continued volatility in freight
volumes, with 2018 likely to see at best a stabilisation of the
negative trend in 2011-2017 (47% cumulative drop), before a
projected gradual rebound in 2019-2022. The projected gradual
recovery of volumes over the medium term is linked to expected
growth of neighbouring economies and a rebound in oil prices.
Fitch forecasts Georgia's GDP growth will accelerate to 5.2% in
2018 (2017: 5%), while Russian, Kazakhstani and Azerbaijani
economies are projected to grow 2%, 3.8% and 2% respectively.

GR's leverage will remain high in 2018-2020, underpinned by
improving but still weaker performance. Fitch estimates GR's net
debt-to-Fitch-calculated EBITDA at about 7x in 2018 (2017: 6.3x),
before a gradual improvement to about 5x in 2022. Fitch expects
no change in the company's consolidated direct debt (2017: GEL1.4
billion), which is linked to capex.

The bulk of GR's debt is denominated in US dollars; nonetheless
FX exposure is partially mitigated by a natural hedge, as about
90% of its revenue is linked to US dollars, while most of the
company's expenditure is in lari. GR's liquidity buffer remains
sound with interim cash reserves estimated to total GEL235
million at end-2018. Fitch expects GR to maintain healthy cash
balances of up to GEL240 million in 2018-2022.

RATING SENSITIVITIES

Developments That May, Individually or Collectively, Lead to
Positive Rating Action

  - An upgrade of Georgia's sovereign rating

  - Greater incentive for state support leading to reassessment
of the socio-political implications of a default and therefore a
narrowing of rating-notch differential

  - A stronger financial profile resulting in the SCP being on a
par with or above the sovereign

Developments That May, Individually or Collectively, Lead to
Negative Rating Action

  - A downgrade of Georgia's sovereign rating

  - Dilution of linkage with the sovereign resulting in the
ratings being further notched down from the sovereign

  - Deterioration of financial profile and liquidity resulting in
downward reassessment of the company's SCP

FULL LIST OF RATING ACTIONS

Long-Term Foreign and Local Currency IDRs affirmed at 'B+'
Outlook revised to Positive from Stable

Short-Term Foreign and Local Currency IDRs affirmed at 'B'

Local currency senior unsecured rating affirmed at 'B+'


=============
I R E L A N D
=============


ARMADA EURO III: Moody's Assigns (P)B2 Rating to Class F Notes
--------------------------------------------------------------
Moody's Investors Service announced that it has assigned the
following provisional ratings to eight classes of notes to be
issued by Armada Euro III Designated Activity Company:

EUR 2,000,000 Class X Senior Secured Floating Rate Notes due
2031, Assigned (P)Aaa (sf)

EUR 218,000,000 Class A-1 Senior Secured Floating Rate Notes due
2031, Assigned (P)Aaa (sf)

EUR 30,000,000 Class A-2 Senior Secured Floating Rate Notes due
2031, Assigned (P)Aaa (sf)

EUR 35,000,000 Class B Senior Secured Floating Rate Notes due
2031, Assigned (P)Aa2 (sf)

EUR 27,000,000 Class C Senior Secured Deferrable Floating Rate
Notes due 2031, Assigned (P)A2 (sf)

EUR 27,000,000 Class D Senior Secured Deferrable Floating Rate
Notes due 2031, Assigned (P)Baa3 (sf)

EUR 23,000,000 Class E Senior Secured Deferrable Floating Rate
Notes due 2031, Assigned (P)Ba2 (sf)

EUR 10,000,000 Class F Senior Secured Deferrable Floating Rate
Notes due 2031, Assigned (P)B2 (sf)

Moody's issues provisional ratings in advance of the final sale
of financial instruments, but these ratings only represent
Moody's preliminary credit opinions. Upon a conclusive review of
a transaction and associated documentation, Moody's will
endeavour to assign definitive ratings. A definitive rating (if
any) may differ from a provisional rating.

RATINGS RATIONALE

Moody's provisional ratings of the rated notes reflect the risks
from defaults on the underlying portfolio of loans given the
characteristics and eligibility criteria of the constituent
assets, the relevant portfolio tests and covenants, as well as
the transaction's capital and legal structure. Furthermore,
Moody's considers that the collateral manager Brigade Capital
Euro Management LLP has sufficient experience and operational
capacity and is capable of managing this CLO.

Armada Euro III is a managed cash flow CLO. At least 90% of the
portfolio must consist of secured senior obligations and up to
10% of the portfolio may consist of unsecured senior loans,
unsecured senior bonds, second lien loans, mezzanine obligations
and high yield bonds. At closing, the portfolio is expected to be
approximately 50% ramped up and to be comprised predominantly of
corporate loans to obligors domiciled in Western Europe. The
remainder of the portfolio will be acquired during the six month
ramp-up period in compliance with the portfolio guidelines.

Brigade Capital will manage the CLO. It will direct the
selection, acquisition and disposition of collateral on behalf of
the Issuer and may engage in trading activity, including
discretionary trading, during the transaction's approximately
four-years reinvestment period. Thereafter, purchases are
permitted using principal proceeds from unscheduled principal
payments and proceeds from the sale of credit risk obligations,
and are subject to certain restrictions.

Interest and principal amortisation amounts due to the Class X
Notes are paid pro rata with payments to the Class A-1 and A-2
Notes. The Class X Notes amortise by EUR 250,000 over the first
eight payment dates.

In addition to the eight classes of notes rated by Moody's, the
Issuer will issue EUR2.00m of Class Z notes and EUR40.40M of
subordinated notes which will not be rated.

The transaction incorporates interest and par coverage tests
which, if triggered, divert interest and principal proceeds to
pay down the notes in order of seniority.

Methodology Underlying the Rating Action:

The principal methodology used in these ratings was "Moody's
Global Approach to Rating Collateralized Loan Obligations"
published in August 2017.

The Credit Ratings of the notes issued by Armada Euro III were
assigned in accordance with Moody's existing Methodology entitled
"Moody's Global Approach to Rating Collateralized Loan
Obligations" dated August 31, 2017. Please note that on November
14, 2018, Moody's released a Request for Comment, in which it has
requested market feedback on potential revisions to its
Methodology for Collateralized Loan Obligations. If the revised
Methodology is implemented as proposed, the Credit Rating of the
notes issued by Armada Euro III may be neutrally affected. Please
refer to Moody's Request for Comment, titled "Proposed Update to
Moody's Global Approach to Rating Collateralized Loan
Obligations" for further details regarding the implications of
the proposed Methodology revisions on certain Credit Ratings.

Factors that would lead to an upgrade or downgrade of the
ratings:

The rated notes' performance is subject to uncertainty. The
notes' performance is sensitive to the performance of the
underlying portfolio, which in turn depends on economic and
credit conditions that may change. The collateral manager's
investment decisions and management of the transaction will also
affect the notes' performance.

Moody's modeled the transaction using CDOEdge, a cash flow model
based on the Binomial Expansion Technique, as described in
Section 2.3 of the "Moody's Global Approach to Rating
Collateralized Loan Obligations" rating methodology published in
August 2017.

Moody's used the following base-case modeling assumptions:

Target Par Amount: EUR 400,000,000.00

Diversity Score: 40

Weighted Average Rating Factor (WARF): 2800

Weighted Average Spread (WAS): 3.55%

Weighted Average Coupon (WAC): 4.75%

Weighted Average Recovery Rate (WARR): 43.75%

Weighted Average Life (WAL): 8.5 years

Moody's has addressed the potential exposure to obligors
domiciled in countries with local currency ceiling (LCC) of A1 or
below. As per the portfolio constraints and eligibility criteria,
exposures to countries with LCC below "A3" cannot exceed 5% and
obligors cannot be domiciled in countries with LCC below "Baa3".


ARROW CMBS 2018: Fitch Assigns B-sf Rating to Class F Notes
-----------------------------------------------------------
Fitch Ratings has assigned ARROW CMBS 2018 DAC's floating-rate
notes final ratings as follows:

EUR135.8 million class A1(XS1906449019): 'AAAsf'; Outlook Stable

EUR19 million class A2 (XS1906449282): 'AA+sf'; Outlook Stable

EUR23 million class B (XS1906450025): 'AA-sf'; Outlook Stable

EUR29.3 million class C (XS1906450454): 'A-sf'; Outlook Stable

EUR32 million class D (XS1906450611): 'BBB-sf'; Outlook Stable

EUR32.7 million class E (XS1906450884): 'BB-sf'; Outlook Stable

EUR20.9 million class F (XS1906450967): 'B-sf'; Outlook Stable

EUR0.4 million class X (XS1906451189): 'NRsf'

The transaction is a 95% securitisation of a EUR308.2 million
commercial real estate loan, originated by Deutsche Bank and
Societe Generale and backed by a Blackstone-sponsored portfolio
of 89 primarily logistics/light industrial and mixed-use assets
located across France, Germany and The Netherlands.

KEY RATING DRIVERS

Granular Portfolio

The portfolio consists of 89 industrial buildings, including both
"big box" and smaller urban logistics assets, as well as some
light industrial units. The geographic spread covers France (53
sites), Germany (27) and The Netherlands (nine). Tenant
concentration is moderate, with most assets being multi-let.
Portfolio income is generated by around 350 tenants across
various sectors, based on physical occupancy of 90.7%.

Diversity Brings Legal Complexity

The portfolio serves growing pan-European logistics markets,
while also featuring smaller units with good transport links into
Paris, Lyon, Lille, Berlin, Munich and The Randstad. Geographic
diversification is credit-positive but also adds legal risk. To
mitigate French safeguard proceedings, the borrower group is held
by a "double luxco" designed to thwart potential hostile borrower
strategies. Limitations on French cross-collateralisation also
create reliance on contractual protections and share pledge.

Functional Assets, High Leverage

The portfolio comprises mostly functional secondary properties
that are generally fit for purpose. Some assets require
modernisation or re-specification, but few fall into Fitch's
weaker quality scores deemed at higher risk of extensive
structural vacancy (grades 5-7 account for 5% of rental value).
While portfolio income is resilient, the senior loan is highly
leveraged, with a 69.7% loan-to-value ratio (LTV) and no
scheduled amortisation.

Mezzanine Loan Constrains Rating

Additional leverage consists of a EUR78.1 million structurally
and contractually subordinated mezzanine loan. Should the senior
loan default, upon certain events, including commencement of
enforcement, the mezzanine lender has 15 business days to elect
to buy the senior loan at par plus accrued interest. The price
excludes any costs incurred for enforcement and may not include
default penalty interest. Given this, and the negative signal to
potential bidders should the purchase not be exercised, the
option's durability constrains the class F rating.

KEY PROPERTY ASSUMPTIONS (all by market value)

'Bsf' weighted average (WA) cap rate: 8.1%

'Bsf' WA structural vacancy: 18.3%

'Bsf' WA rental value decline: 2.6%

'BBsf' WA cap rate: 8.7%

'BBsf' WA structural vacancy: 20.5%

'BBsf' WA rental value decline: 4.9%

'BBBsf' WA cap rate: 9.3%

'BBBsf' WA structural vacancy: 22.8%

'BBBsf' WA rental value decline: 7.6%

'Asf' WA cap rate: 10%

'Asf' WA structural vacancy: 25.1%

'Asf' WA rental value decline: 10.4%

'AAsf' WA cap rate: 10.7%

'AAsf' WA structural vacancy: 27.8%

'AAsf' WA rental value decline: 13.6%

'AAsf' WA cap rate: 11.5%

'AAsf' WA structural vacancy: 31.6%

'AAsf' WA rental value decline: 16.9%

RATING SENSITIVITIES

The change in model output that would apply if the capitalisation
rate assumption for each property is increased by a relative
amount is as follows:

Current ratings: 'AAAsf'/'AA+sf'/'AA-sf'/'A-sf'/'BBB+sf'/'BB-
sf'/'B-sf'

Increase capitalisation rates by 10%: 'AA+sf'/'AA-
sf'/'Asf'/'BBBsf'/'BBsf'/'Bsf'/'CCCsf'

Increase capitalisation rates by 20%:
'AAsf'/'A+sf'/'BBB+sf'/'BB+sf'/'BB+sf'/'CCCsf'/'CCCsf'

The change in model output that would apply if the rental value
decline (RVD) and vacancy assumption for each property are
increased by a relative amount is as follows:

Increase RVD and vacancy by 10%: 'AA+sf'/'AA-
sf'/'Asf'/'BBBsf'/'BB+sf'/'B+sf'/'CCCsf'

Increase RVD and vacancy by 20%: 'AAsf'/'A+sf'/'A-sf'/'BBB-
sf'/'BBsf'/'Bsf'/'CCCsf'

The change in model output that would apply if the capitalisation
rate, RVD and vacancy assumptions for each property are increased
by a relative amount is as follows:

Increase in all factors by 10%: 'AAsf'/'A+sf'/'A-sf'/'BBB-
sf'/'BB-sf'/'CCCsf'/'CCCsf'

Increase in all factors by 20%: 'A+sf'/'BBB+sf'/'BBB-sf'/'BB-
sf'/'Bsf'/'CCCsf'/'CCCsf'

USE OF THIRD-PARTY DUE DILIGENCE PURSUANT TO RULE 17G-10

Form ABS Due Diligence-15E was not provided to, or reviewed by,
Fitch in relation to this rating action.

DATA ADEQUACY

Fitch reviewed the results of a third-party assessment conducted
on the asset portfolio information, and concluded that there were
no findings that affected the rating analysis.

Overall, Fitch's assessment of the asset pool information relied
upon for the agency's rating analysis according to its applicable
rating methodologies indicates that it is adequately reliable.


GRIFFITH PARK: Moody's Assigns B2 Rating to Class E-R Notes
-----------------------------------------------------------
Moody's Investors Service announced that it has assigned the
following definitive ratings to notes issued by Griffith Park CLO
Designated Activity Company:

EUR 3,000,000 Class X Senior Secured Floating Rate Notes due
2031, Definitive Rating Assigned Aaa (sf)

EUR 264,000,000 Class A-1A-R Senior Secured Floating Rate Notes
due 2031, Definitive Rating Assigned Aaa (sf)

EUR 8,750,000 Class A-1B-R Senior Secured Floating Rate Notes due
2031, Definitive Rating Assigned Aaa (sf)

EUR 20,500,000 Class A-2A-R Senior Secured Floating Rate Notes
due 2031, Definitive Rating Assigned Aa2 (sf)

EUR 20,000,000 Class A-2B-R Senior Secured Fixed Rate Notes due
2031, Definitive Rating Assigned Aa2 (sf)

EUR 16,400,000 Class B1-R Senior Secured Deferrable Floating Rate
Notes due 2031, Definitive Rating Assigned A2 (sf)

EUR 15,000,000 Class B2-R Senior Secured Deferrable Floating Rate
Notes due 2031, Definitive Rating Assigned A2 (sf)

EUR 26,900,000 Class C-R Senior Secured Deferrable Floating Rate
Notes due 2031, Definitive Rating Assigned Baa3 (sf)

EUR 24,450,000 Class D-R Senior Secured Deferrable Floating Rate
Notes due 2031, Definitive Rating Assigned Ba3 (sf)

EUR 11,250,000 Class E-R Senior Secured Deferrable Floating Rate
Notes due 2031, Definitive Rating Assigned B2 (sf)

RATINGS RATIONALE

Moody's definitive ratings of the rated notes reflect the risks
from defaults on the underlying portfolio of loans given the
characteristics and eligibility criteria of the constituent
assets, the relevant portfolio tests and covenants, as well as
the transaction's capital and legal structure. Furthermore,
Moody's considers that the collateral manager Blackstone / GSO
Debt Funds Management Europe Limited has sufficient experience
and operational capacity and is capable of managing this CLO.

The Issuer issued the refinancing notes in connection with the
refinancing of the following classes of notes: Class A-1 Notes,
Class A-2A Notes, Class A-2B Notes, Class B Notes, Class C Notes,
Class D Notes and Class E Notes due 2029, previously issued on
September 08, 2016. On the refinancing date, the Issuer has used
the proceeds from the issuance of the refinancing notes to redeem
in full the Original Notes.

On the Original Closing Date, the Issuer also issued EUR 48.7
million of subordinated notes, which will remain outstanding. The
terms and conditions of the subordinated notes have been amended
in accordance with the refinancing notes' conditions.

Interest and principal amortisation amounts due to the Class X
Notes are paid pro rata with payments to the interest amount due
to the Class A-1A-R Notes. Prior to a Frequency Switch Event, the
Class X Notes amortise by 12.5% or EUR 375,000 over the first 8
payment dates, starting on the 1st payment date. Following the
occurrence of a Frequency Switch Event (which is continuing), the
Class X Notes amortise by EUR 750,000 in each payment date.

Interest and principal payments due to the Class A-1B-R Notes are
subordinated to interest and principal payments due to the Class
X Notes and the Class A-1A-R Notes.

As part of this reset, the Issuer has set the reinvestment period
to 4.5 years and the weighted average life to 8.5 years. In
addition, the Issuer has amended the base matrix and modifiers
that Moody's has taken into account for the assignment of the
definitive ratings.

The Issuer is a managed cash flow CLO. For as long as Class A-1A-
R Notes remain outstanding, at least 96% of the portfolio must
consist of secured senior loans or senior secured notes and up to
4% of the portfolio may consist of unsecured senior obligations,
second-lien loans, mezzanine obligations, high yield bonds and
first lien last out loans; thereafter, at least 90% of the
portfolio must consist of secured senior loans or senior secured
notes and up to 10% of the portfolio may consist of unsecured
senior obligations, second-lien loans, mezzanine obligations,
high yield bonds and first lien last out loans; the underlying
portfolio is expected to be approximately 99.4% ramped as of the
closing date. The issuer will apply approximately EUR 1.2 million
of proceeds from the issuance of refinancing notes to the
purchase of additional collateral obligations in order to fully
ramp-up the portfolio to the target par amount.

Blackstone / GSO will manage the CLO. It will direct the
selection, acquisition and disposition of collateral on behalf of
the Issuer and may engage in trading activity, including
discretionary trading, during the transaction's 4.5-year
reinvestment period. Thereafter, purchases are permitted using
principal proceeds from unscheduled principal payments and
proceeds from sales of credit risk obligations, and are subject
to certain restrictions.

The transaction incorporates interest and par coverage tests
which, if triggered, divert interest and principal proceeds to
pay down the notes in order of seniority.

Methodology Underlying the Rating Action:

The principal methodology used in these ratings was "Moody's
Global Approach to Rating Collateralized Loan Obligations"
published in August 2017.

Factors that would lead to an upgrade or downgrade of the
ratings:

The rated notes' performance is subject to uncertainty. The
notes' performance is sensitive to the performance of the
underlying portfolio, which in turn depends on economic and
credit conditions that may change. The collateral manager's
investment decisions and management of the transaction will also
affect the notes' performance.

Moody's modeled the transaction using CDOEdge, a cash flow model
based on the Binomial Expansion Technique, as described in
Section 2.3 of the "Moody's Global Approach to Rating
Collateralized Loan Obligations" rating methodology published in
August 2017.

Moody's used the following base-case modeling assumptions:

Target Par Amount: EUR 440,000,000

Diversity Score: 44

Weighted Average Rating Factor (WARF): 2836

Weighted Average Spread (WAS): 3.45%

Weighted Average Coupon (WAC): 4.00%

Weighted Average Recovery Rate (WARR): 44%

Weighted Average Life (WAL): 8.5 years

Moody's has addressed the potential exposure to obligors
domiciled in countries with local currency ceiling (LCC) of A1 or
below. As per the portfolio constraints and eligibility criteria,
exposures to countries with LCC of A1 to A3 cannot exceed 10% and
obligors that are domiciled in countries with LCC below A3 cannot
be purchased.


=========
I T A L Y
=========


ITALY: Rising Bond Yields to Threaten Stability of Banks
--------------------------------------------------------
Kate Allen at The Financial Times reports that Italy's central
bank has sounded the alarm over the country's rising bond yields,
warning that they are set to cost the nation billions a year in
additional interest payments on its debt and could threaten the
stability of banks and insurers.

Italian sovereign bond yields have ratcheted upwards as investors
have taken fright at the populist coalition government's plans to
increase public spending even after the EU rejected its draft
budget over worries about the country's vast debt burden, the FT
discloses.

According to the FT, in a financial stability report published on
Nov. 23, the Bank of Italy said "uncertainty about the economic
and fiscal policy stance" was undermining banks and insurers.

Banks have seen a deterioration in "liquidity and capital
adequacy indicators", it said, while a further sell-off could
have "significant effects on the solvency position of insurers"
and "heighten the risks to stability", the FT relates.

Sovereign debt yields hit their highest levels since 2014 last
month as the EU threatened sanctions over Italy's draft budget,
reflecting worries over lending to a government with the second-
largest debt as a proportion of gross domestic product in the
eurozone after Greece, the FT recounts.

The central bank estimated that if Italian bond yields remain at
current levels, the country will pay an additional EUR9 billion a
year in interest costs on its debt by 2020, the FT notes.  The
rise in bond yields threatens the government's plan to stimulate
the economy by increasing public spending, it warned, while
making it more expensive for Italian companies to borrow, the FT
states.


PIAGGIO AEROSPACE: Italian Government Aims to Protects Jobs
-----------------------------------------------------------
Reuters reports that Italy's Prime Minister Giuseppe Conte said
on Nov. 23 that the government's priority is to protect jobs at
Italian aircraft maker Piaggio Aerospace, and will discuss the
matter in the coming hours.

Piaggio Aerospace has asked the government to be put under
special administration after a 2017 turnaround plan failed to
produce the expected results, Reuters relates.

The company, a unit of Abu Dhabi's sovereign fund Mubadala, is
developing unmanned drones, Reuters states.

In 2017, it started talks to sell its executive P180 turbojet
business to PAC Investments, a Chinese state-backed consortium,
an operation which raised concerns over the transfer of sensitive
technology and potential loss of jobs, Reuters discloses.


===========
P O L A N D
===========


GETIN NOBLE: Fitch Puts B- IDR on Rating Watch Negative
-------------------------------------------------------
Fitch Ratings has placed Getin Noble Bank SA's (Getin) Long-Term
Issuer Default Rating (IDR) of 'B-' on Rating Watch Negative
(RWN).

The RWN reflects heightened risk of a downgrade due to its
assessment that the bank's liquidity risk has increased. The bank
is experiencing deposit withdrawals and negative media focus
could aggravate the situation, in its view.

KEY RATING DRIVERS

IDRS, VIABILITY RATING, NATIONAL RATING

Getin's IDRs and National Rating are driven by its standalone
strength, as reflected in its Viability Rating (VR).

Fitch downgraded the bank on November 14. The downgrades of
Getin's VR and IDRs reflected Fitch's opinion that Getin's
viability prospects had weakened due to heightened capitalisation
pressure. The bank breached its minimum regulatory capital
requirements in 1H18, mainly due to a combination of high losses
and increased capital requirements (predominantly related to
foreign-currency (FC) mortgages).

The downgrade coincided with increased media attention following
statements made by the bank's majority shareholder, Mr. Leszek
Czarnecki, regarding alleged bribe solicitations made by the head
of Poland's financial regulator. Getin has experienced deposit
outflow since mid-November. Since the last rating action on
November 14, Fitch has now revised downwards its assessment of
the bank's funding and liquidity profile.

Getin has not provided us with its latest information on
liquidity and deposit flows but in its view this limitation is
not sufficiently material to limit its ability to continue to
assign ratings to the bank at their current level even
considering the recent nature of relevant news flow.

Its assessment of Getin's funding and liquidity profile already
considered the relative weakness in its customer relationships,
as demonstrated by a high share of term deposits (72% of retail
savings at end-1H18). Getin's liquidity buffer equalled about 11%
of assets and the liquidity coverage ratio was 129% at end-1H18.
This buffer is likely to have deteriorated since that date due to
deposit outflows. No official statements regarding the provision
of extraordinary liquidity support to Getin have been made and
media reports do not suggest a heightened pace of deposit
withdrawals.

RATING SENSITIVITIES

IDRS, VIABILITY RATING, NATIONAL RATING

Getin's ratings could be downgraded if Fitch assesses there has
been a further material deterioration in its liquidity profile.
In its previous rating action commentary, Fitch also highlighted
that Getin's ratings are primarily sensitive to its ability to
execute its recapitalisation plan by end-2019 and to be able to
generate sufficient capital to reach regulatory minimum
requirements in a timely manner. Its ability to achieve this is
sensitive to an improvement in structural profitability, as well
as to a reduction in LICs.

If the bank continues to face an extended period of uncertainty
and Fitch is unable to obtain sufficient information on its
liquidity profile, this could result in a withdrawal of Getin's
ratings.

Given the RWN, upside potential is currently limited. However,
should the current news flow abate without material impact on the
bank's funding and liquidity profile, the ratings could be
upgraded. This would require strengthening of Getin's capital
ratios above the regulatory minimums coupled with a record of
restored profit generation capacity. A material reduction in
impaired loans, repossessed assets and FC mortgages would also be
rating positive.

The rating actions are as follows:

Long-Term IDR: 'B-' placed on RWN

Short-Term IDR: 'B' placed on RWN

National Long-Term Rating: 'BB-(pol)' placed on RWN

Viability Rating: 'b-' placed on RWN

Support Rating: '5' unaffected

Support Rating Floor: 'No Floor' unaffected


IDEON SA: Opts to Continue Restructuring Process
------------------------------------------------
Reuters reports that Ideon SA said on Nov. 22 that due to the end
of its insolvency recovery proceedings carried out since 2013 it
has decided to continue restructuring process based on
restructuring law.

According to Reuters, in the near future, the company plans to
prepare detailed restructuring plan and put forward arrangement
proposals to its debtors.

Ideon SA is based in Poland.


===========
R U S S I A
===========


EVRAZ GROUP: Moody's Upgrades CFR to Ba1, Outlook Stable
--------------------------------------------------------
Moody's Investors Service has upgraded Evraz Group S.A.'s
corporate family rating to Ba1 from Ba2, probability of default
rating to Ba1-PD from Ba2-PD and senior unsecured rating assigned
to the notes issued by Evraz to Ba2 from Ba3. The outlook on
Evraz's ratings is stable.

"We have upgraded Evraz's ratings based on continuing reduction
in its leverage and total debt, and our expectation that it will
be able to keep leverage sustainably within our threshold for its
Ba1 rating, will adhere to its balanced financial policy and
maintain healthy liquidity," says Artem Frolov, a Vice President
- Senior Credit Officer at Moody's.

RATINGS RATIONALE

The upgrade of Evraz's rating to Ba1 reflects Moody's expectation
that Evraz will (1) maintain its Moody's-adjusted total
debt/EBITDA below 2.5x on a sustainable basis; (2) continue to
gradually reduce total debt amount and be able to generate
sustainable positive post-dividend free cash flow; (3) adhere to
its balanced financial policy and tailor its dividend payouts to
the steel and coking coal market pricing environment and capital
spending; and (4) continue to maintain healthy liquidity and
pursue conservative liquidity management.

As of June 30, 2018, Evraz's leverage expectedly declined to 1.5x
from 2.1x at year-end 2017 and 4.0x at year-end 2016. The decline
in leverage was driven primarily by the 29% increase in the
company's Moody's-adjusted EBITDA in the 12 months ended June 30,
2018, to $3.4 billion, compared with $2.6 billion in 2017, due to
continuing high steel and coking coal prices, as well as ongoing
reduction in Moody's-adjusted total debt amount by 12% to $5.0
billion. Moody's expects Evraz's leverage to remain below 2.0x
over the next 12-18 months, assuming a moderate decline in steel,
coking coal and vanadium prices in 2019-20 from their year-to-
date average levels which Moody's views as unsustainably high.

The company's EBITDA and, consequently, leverage are sensitive to
the volatile prices of steel, coking coal and, to a lesser
extent, vanadium. Owing to the particularly favourable pricing
environment in 2018, including the recent increase in vanadium
prices, and reduced total debt amount, the company has built a
comfortable leverage headroom. If prices were to materially
decline from 2019 (although this is not Moody's central
scenario), Evraz's leverage would likely grow to around 2.5x only
in 2020, all else being equal. Evraz's EBITDA and leverage are
also sensitive to the RUB/USD exchange rate, but Moody's does not
expect any major rouble appreciation, which would negatively
affect Evraz, over the next 12-18 months amid the persistent
threat of sanctions against Russian corporates, banks and
sovereign debt.

Evraz's Ba1 rating also factors in (1) the company's profile as a
low-cost integrated steelmaker, including low cash costs of
coking coal and iron ore production, and a large low-cost
producer of vanadium; (2) its high self-sufficiency in iron ore
and coking coal; (3) its product, operational and geographical
diversification; (4) its strong market position in long steel
products in Russia, including leadership in rail manufacturing,
large diameter pipes and rails in North America, and vanadium
globally; (5) the sustained demand for Evraz's steel products in
Russia, and oil country tubular goods (OCTG) and rails in North
America; (6) the company's financial policy which anticipates
maintaining net debt below $4 billion and net debt/EBITDA below
2.0x; and (7) the company's long-term debt maturity profile and
strong liquidity.

At the same time, Evraz's rating takes into account (1) the fact
that the company's public guidance indicates only minimum
dividend amount and a leverage cap but lacks any target dividend
payout ratio, which creates uncertainty over the company's post-
dividend free cash flow, although Moody's expects Evraz to tailor
its dividend payouts to the steel and coking coal market pricing
environment and capital spending; (2) the sluggish demand for
steel in the Russian construction sector, which is the major
consumer of Evraz's steel products, although Moody's expects this
demand to improve over the next 12-18 months, supported by the
state initiatives to develop infrastructure and boost residential
construction, and tightening of residential construction
regulations from July 2019 which stimulates developers to launch
new projects beforehand; (3) the overall negative effect of the
25% steel import tariff, imposed by the US in March 2018 and
Canada in October 2018, on Evraz's business in North America,
although Moody's does not expect it to have any material effect
on Evraz's consolidated financial performance; (4) the company's
plan to increase capital spending in 2019-22; and (5) continued
volatility in prices of steel, coking coal and vanadium.

The Ba2 rating of Evraz's senior unsecured notes is one notch
below the company's CFR. This differential reflects Moody's view
that the notes are structurally subordinated to more senior
obligations of the Evraz group, primarily to unsecured borrowings
at the level of the group's operating companies, including its
two core steelmaking plants Evraz NTMK and Evraz ZSMK.

RATIONALE FOR THE STABLE OUTLOOK

The stable outlook reflects the company's solid positioning
within the current rating category, despite the volatility in
steel, coking coal and vanadium prices and generous dividend
payouts.

WHAT COULD CHANGE THE RATINGS UP/DOWN

Moody's could upgrade Evraz's ratings if the company (1)
maintains its Moody's-adjusted total debt/EBITDA below 1.5x on a
sustainable basis; (2) adheres to balanced financial policies and
generates sustainable positive post-dividend free cash flow; and
(3) continues to pursue conservative liquidity management and
maintains healthy liquidity.

Moody's could downgrade the ratings if the company's (1) Moody's-
adjusted total debt/EBITDA rises towards 3.0x on a sustained
basis; (2) post-dividend free cash flow becomes sustainably
negative; or (3) liquidity and liquidity management deteriorate
materially.

PRINCIPAL METHODOLOGY

The principal methodology used in these ratings was Steel
Industry published in September 2017.

Evraz is one of the largest vertically integrated steel, mining
and vanadium companies in Russia. The company's main assets are
steel plants and rolling mills (in Russia, North America, Europe
and Kazakhstan), iron ore and coal mining facilities, as well as
trading assets. In the 12 months ended June 30, 2018, Evraz
generated revenue of $12.1 billion (2017: $10.8 billion) and
Moody's-adjusted EBITDA of $3.4 billion (2017: $2.6 billion).
EVRAZ plc currently holds 100% of the company's share capital and
is jointly controlled by Roman Abramovich (30.52%), Alexander
Abramov (20.69%), Alexander Frolov (10.33%), Gennady Kozovoy
(5.80%) and Alexander Vagin (5.74%).


GAZPROMBANK JSC: Fitch Affirms BB+ Long-Term IDR, Outlook Pos.
--------------------------------------------------------------
Fitch Ratings has affirmed the Long-Term Foreign- and Local-
Currency Issuer Default Ratings of Sberbank of Russia (Sberbank),
Vnesheconombank and their leasing subsidiaries, Sberbank Leasing
and JSC VEB-Leasing, at 'BBB-'. Fitch has also affirmed the
Long-Term IDRs of Gazprombank JSC and its subsidiary Gazprombank
(Switzerland) Ltd at 'BB+'. The Outlooks on the IDRs of all six
entities are Positive.

KEY RATING DRIVERS

IDRS, SUPPORT RATINGS, SUPPORT RATING FLOORS (SRFs)

The affirmation of the Long-Term Foreign Currency IDRs and
Support Rating Floors (SRFs) of Sberbank and VEB at the sovereign
level of 'BBB-', and those of GPB at 'BB+', reflects Fitch's view
of a very high propensity of the Russian authorities to support
the banks, in case of need. This is due to:

(i) majority state ownership (100% of VEB is government-owned;
50%+1 share in Sberbank is owned by the Central Bank of Russia
(CBR)), or a high degree of state control and supervision by
quasi-sovereign entities (GPB), most significantly by the bank's
founder and shareholder PJSC Gazprom (BBB-/Positive);

(ii) the exceptionally high systemic importance of Sberbank, as
expressed by its dominant market shares (approximately 35% of
system loans and 45% of retail deposits at end-3Q18), VEB's
status as a development bank and GPB's high systemic importance
for the banking sector;

(iii) the track record of capital support to VEB and GPB to date;
and

(iv) the high reputational risks of a potential default for the
Russian authorities/state-controlled shareholders.

The Positive Outlooks on all three state-owned banks reflect that
on the sovereign.

The affirmation of VEB's ratings also reflects Fitch's
expectation that the bank will receive sufficient and timely
government support in the near- to medium-term to address
weaknesses in its solvency and liquidity and enable it to service
its obligations to creditors. VEB already received about RUB1.1
trillion capital support from the state in 2015-1H18 (including
equity injections, subsidies and provision reversal on Ukrainian
exposures due to a RUB0.4 trillion guarantee from the state in
2016).

VEB expects to receive a RUB20 billion capital contribution by
end-2018 and a further RUB300 billion of new equity from the
government in 2019-2021, according to the state budget, which
should be enough to both cover remaining problem loans (estimated
at about RUB300 billion net of reserves and excluding state-
guaranteed exposures) and medium-term external debt repayments.
VEB's capital position could be additionally supported by
recently approved callable capital of RUB300 billion. Longer-term
debt (maturing after 2021) may be covered with additional capital
contributions of RUB300 billion, as recently stated by the
Russian Prime Minister Dmitry Medvedev, who also chairs VEB's
board of directors. VEB's foreign wholesale funding was USD10
billion (22% of consolidated liabilities) at end-1H18, including
a USD850 million Eurobond repaid subsequently in November 2018.
The next significant repayment of Eurobonds (USD1.6 billion) is
expected in 2020.

The ratings of GPB are one notch lower than those of Sberbank and
VEB as the bank does not have the exceptional systemic importance
of the former or the development bank status of the latter. The
notching from the sovereign also reflects (i) delays in provision
of core equity support, and its potential remaining capital
needs; and (ii) non-direct state ownership and a complex
shareholding structure.

The affirmation of the IDRs of Sberbank-Leasing, VEB Leasing and
GPBS in line with those of their parents reflects Fitch's view
that they are highly-integrated core subsidiaries.

DEBT RATINGS

The senior unsecured debt ratings are aligned with the banks'
IDRs.

State banks' subordinated debt issues (including 'new style') are
notched down once from the banks' IDRs, The notching reflects
below-average recovery prospects for all subordinated instruments
in case of default. Fitch notches 'new style' subordinated debt
issues from the banks' IDRs, rather than from the banks'
Viability Ratings (VR), because of a track record of pre-emptive
capital support to Russian state banks, suggesting that the non-
performance risk of subordinated debt is likely to be close to
that of senior unsecured debt.

The ratings of debt issued by Sberbank, VEB, GPB and their
subsidiaries apply to debt issued prior to August 1, 2014.

VIABILITY RATINGS

SBERBANK

The VR of Sberbank reflects its dominant position in the Russian
banking sector and its very granular and reliably cheap funding
base, giving it significant pricing power and translating into
consistently strong performance. At the same time, as the bank's
business is concentrated in Russia with significant exposure to
the sovereign and state-owned entities, while its performance is
correlated with that of the broader economy and the sovereign.

At end-3Q18 Sberbank's impaired loans (defined as stage 3 and
POCI loans under IFRS 9) equalled to 8.4% of end-3Q18 gross
loans, which is below the sector average of 11%, and were 69.7%
covered with specific loan loss allowances (LLA). Stage 2 loans
equalled a further 11.6% of end-3Q18 gross loans, covered by 7.3%
with LLA, which is close to the market average. Fitch expects
asset quality to remain stable in the near term given relatively
low-risk largest corporate lending, high Stage 3 LLA coverage and
only moderate credit risks in retail.

Sberbank consistently outperforms the banking sector and its
annualised pre-impairment profit exceeded 6% of average gross
loans in 9M18, providing the bank with significant loss
absorption capacity. Loan impairment charges are expected to stay
at around 1.5% of average gross loans (assuming stability in the
broader economy). This is well below the pre-impairment profit,
which should allow Sberbank to post good returns on average
equity of around 20% in the next few years.

Despite its Fitch Core Capital (FCC) ratio equalling only a
moderate 11.9% at end-3Q18, Fitch views Sberbank's capitalisation
as reasonable due to high risk-weighted assets density (at end-
3Q18 risk-weighted assets (RWAs) equaled to a high 103% of total
assets) and robust profitability. Although Sberbank expects to
increase its dividend pay-out ratio to 50% by 2020, profit
retention should be sufficient to keep the capital ratio close to
the targeted 12.5% level.

Sberbank's exceptionally strong funding profile is a key rating
strength. Sberbank is mainly customer-funded (77% of total
liabilities at end-3Q18) with a significant share of current
accounts (27% of customer funding at end-3Q18) translating into
low funding cost. Contractual wholesale debt repayments in 4Q18-
2019 are limited. SBR's liquidity buffer exceeded 31% of customer
funding or 24% of total liabilities at end-3Q18.

GPB

The affirmation of GPB's VR at 'bb-' reflects a strong franchise,
with lending to high profile corporate clients and attracting
stable, albeit concentrated, funding from them. The rating is
constrained by a somewhat higher risk appetite than higher-rated
peers', by vulnerable asset quality due to large impaired, albeit
improving, legacy corporate exposures and investments in non-core
businesses (mostly, media and industrial holdings) with mixed
performance, and by a tightly managed capital position.

Impaired loans stood at a moderate 7% of gross loans at end-1H18
and were 73% covered by LLAs. They consisted of Stage 3 loans (4%
of gross loans) and POCI loans (a further 3%), which are also
credit-impaired. Excluded from impaired loans was RUB244 billion
(6.4% of loans, 60% of loss-absorbing capital, net of LLAs) of
previously problem exposures reclassified into Stage 1 category
due to a guarantee from a sovereign-related entity (with a
sovereign-level credit rating). Fitch understands from management
that the guarantee provides temporary capital relief, while cash
recoveries on the exposures are currently uncertain.

Additional asset quality risks stems from GPB's large equity
investments (RUB127 billion net of goodwill) and debt exposure
(RUB232 billion) to non-core subsidiaries (together accounting
for 95% of loss-absorbing capital at end-1H18, according to the
separate financial reporting of the banking segment of the
group).

Market risk appetite is also high due to GPB's equity investments
(which alone totalled RUB193 billion at end-1H18, or 51% of loss-
absorbing capital), including a 19% stake in PJSC Megafon
(BB+/Stable; 16% of loss-absorbing capital), a 37% stake in the
closed investment fund Gazprombank-Finansovyi (7% of loss-
absorbing capital), the assets of which mostly consisted of PJSC
Transneft's preference shares, and a 49% stake in the subsidiary
of one of GPB's largest borrowers (another 7%). The latter is a
metals and mining company, whose debt owed to GPB (28% of loss-
absorbing capital) was restructured four years ago.

Capitalisation is a rating weakness given the bank's impaired
exposures and equity holdings. Loss-absorbing capital, which
includes hybrid capital instruments - RUB166 billion preference
shares owned by Russia's Finance Ministry and Deposit Insurance
Agency, was 7.5% of end-1H18 Basel I RWAs. Fitch Core Capital,
which excludes hybrid capital instruments, was only 4% of RWAs.
However, the bank's capital is additionally underpinned by a
large junior debt cushion consisting of additional Tier 1
perpetual debt (including that raised in August and October 2018)
and Tier 2 subordinated debt, which together equalled to RUB282
billion or 6% of end-1H18 RWAs.

Regulatory capital ratios were moderately above the minimums
including buffers at October 1, 2018: core Tier 1, Tier 1 and
total capital ratios of the banking group were at 8.4%, 9.1% and
12.3%. To fully comply with higher buffer requirements applicable
in 2019 (up to 3.5% from current 2.525%) GPB has to raise at
least RUB24 billion of Tier 1 capital, which is manageable given
the recent track record of capital support from PJSC Gazprom.
According to management, GPB plans to raise at least RUB40
billion of perpetual debt during 2019.

Liquidity cushion remains sizeable with cash and short-term bank
placements covering 24% of liabilities at end-1H18, while
unpledged debt securities and loans eligible for repo with the
CBR comprised a further 13%. Refinancing risk is small, as
wholesale debt repayments in 2019 were only 3% of end-1H18
liabilities.

VEB

Fitch does not assign a VR to VEB, similar to other development
banks, as its business model is entirely dependent on the support
of the state and, in its view, its unique policy role cannot be
carried out on a commercial basis.

RATING SENSITIVITIES

IDRS, SRs, SRFs

Rating actions on the IDRs of all entities will most likely
mirror those on Russia's sovereign ratings. Additional downside
pressure on VEB's and GPB's support-driven ratings could emerge
in case of weaker support track record to these entities being
insufficient to address capital/asset quality issues. In this
case the notching between their and the sovereign ratings may be
widened.

Although not a base case scenario, the SRFs of all four entities
could be revised lower, leading to the downgrade of the IDRs of
VEB and GPB, in case of new, more severe sanctions against
Russia, and if Fitch takes a view that it results in weaker
sovereign propensity to support foreign creditors of state-owned
banks.

A significant weakening of the propensity of parent banks to
provide support (not expected by Fitch at present) to subsidiary
entities could result in downgrades of the subsidiaries' ratings.

DEBT RATINGS

The senior unsecured and subordinated debt ratings would likely
change in tandem with the respective banks' Long-Term IDRs.

VRs

An upgrade of Sberbank's VR could be triggered by a sovereign
upgrade, as Fitch believes that Sberbank's intrinsic credit
strength is close to and correlated with that of the sovereign. A
downgrade of Sberbank's VR could be driven by a sharp
deterioration of the operating environment and consequently
Sberbank's asset quality, although Fitch views this as fairly
unlikely at present.

An upgrade of GPB's VR would require a substantial improvement in
asset quality and capitalisation. Conversely, the bank could be
downgraded in case of significant deterioration of these metrics
if this is not promptly offset by new capital support from the
sovereign.

The rating actions are as follows:

Sberbank of Russia

Long-Term Foreign- and Local-Currency IDRs: affirmed at 'BBB-';
Outlooks Positive

Short-Term Foreign- and Local-Currency IDRs: affirmed at 'F3'

Viability Rating: affirmed at 'bbb-'

Support Rating: affirmed at '2'

Support Rating Floor: affirmed at 'BBB-'

SB Capital S.A.

Senior unsecured debt: affirmed at 'BBB-'

'Old-style and 'New-style' subordinated debt: affirmed at 'BB+'

Vnesheconombank

Long-Term Foreign- and Local-Currency IDRs: affirmed at 'BBB-';
Outlooks Positive

Short-Term Foreign-Currency IDR: affirmed at 'F3'

Support Rating: affirmed at '2'

Support Rating Floor: affirmed at 'BBB-'

Senior unsecured debt: affirmed at 'BBB-'

VEB Finance PLC:

Senior unsecured debt: affirmed at 'BBB-'

Gazprombank JSC:

Long-Term Foreign- and Local-Currency IDRs: affirmed 'BB+';
Outlooks Positive

Short-Term Foreign-Currency IDR: affirmed at 'B'

Viability Rating: affirmed at 'bb-'

Support Rating: affirmed at '3'

Support Rating Floor: affirmed at 'BB+'

Senior unsecured debt: affirmed at 'BB+'

GPB Eurobond Finance PLC:

Senior unsecured debt: affirmed at 'BB+'

'Old-style and 'New-style' subordinated debt: affirmed at 'BB'

Gazprombank (Switzerland) Ltd

Long-Term Foreign-Currency IDR: affirmed at 'BB+'; Outlook
Positive

Short-Term Foreign-Currency IDR: affirmed at 'B'

Support Rating: affirmed at '3'

Sberbank Leasing

Long-Term Foreign- and Local-Currency IDRs: affirmed at 'BBB-';
Outlooks Positive

Short-Term Foreign-Currency IDR: affirmed at 'F3'

Support Rating: affirmed at '2'

JSC VEB-Leasing

Long-Term Foreign- and Local-Currency IDRs: affirmed at 'BBB-';
Outlooks Positive

Short-Term Foreign-Currency IDR: affirmed at 'F3'

Support Rating: affirmed at '2'

Senior unsecured debt: affirmed at 'BBB-'


=========
S P A I N
=========


DISTRIBUIDORA INTERNACIONAL: Moody's Cuts CFR to B2, Outlook Neg.
-----------------------------------------------------------------
Moody's Investors Service has downgraded the long-term corporate
family rating of Spanish grocer Distribuidora Internacional de
Alimentacion to B2 from Ba2 and its probability of default rating
to B2-PD from Ba2-PD. Moody's has also downgraded to B2 from Ba2
DIA's senior unsecured long-term ratings. The outlook is
negative.

"Our downgrade of DIA's ratings and outlook change reflect the
company's earnings trajectory and weakened liquidity," says
Vincent Gusdorf, a Moody's Vice President - Senior Analyst and
lead analyst for DIA. "DIA has yet to refinance its upcoming debt
maturities and amend its covenants, which we believe could
pressure its liquidity in the coming months, although we
acknowledge that DIA continues to negotiate with its banks," Mr
Gusdorf added.

RATINGS RATIONALE

The rating action reflects Moody's view that DIA's credit quality
has deteriorated sharply, reflecting a set of circumstances which
will weigh on its earnings and liquidity such that DIA's ratings
are no longer commensurate with a Ba2 rating. DIA's profits and
cash flows will contract significantly over the next 12 months
because of declining market shares in Iberia and adverse currency
effects.

As a result, DIA's liquidity could come under significant
pressure if it does not find new sources of financing and reset
its covenant. The company had EUR132 million of cash on September
30, 2018 compared to EUR757 million of short-term debt. While it
also had EUR460 million of undrawn credit facilities, EUR376
million were made of syndicated facilities subject to a reported
net debt to EBITDA covenant of 3.5x that the company will likely
breach at the next testing date, around February 2019.

Liquidity has depleted quickly in recent weeks because of a
profit warning and the revelation of accounting errors. On
October 15, 2018, DIA announced that its company-adjusted EBITDA
would drop to EUR350-400 million in 2018 from EUR568 million in
2017. Moody's foresees that earnings will continue to fall in
2019 as well, albeit at a slower pace, because DIA faces
headwinds in all of its markets, which will not be fully offset
by cost-cutting measures. In addition, DIA indicated on October
22, that it will restate its 2017 equity by EUR57 million, mostly
because of incorrect accounting of commercial discounts and
invoices from suppliers.

While DIA has started negotiating new sources of financing with
its banks, the outcome of this process remains uncertain at this
stage. The current B2 rating assumes that DIA will not attempt to
restructure its debt or take any action that the rating agency
would consider as a distressed exchange.

In addition, the rating agency estimates that DIA's gross
debt/EBITDA ratio will rise significantly to nearly 6x in 2019,
compared to 3.7x in 2017, on a Moody's-adjusted basis. Because of
the competition of market leader Mercadona and German discounter
Lidl, DIA's market share in Spain declined by 70 basis points in
August 2018, based on an average of the previous three months,
according to research firm Kantar Worldpanel. As a result, the
company-adjusted EBITDA fell by 12% in Iberia during the first
nine months of 2018. In Latin America, the company-adjusted
EBITDA margin fell by 50 basis points, excluding the effects of
the new accounting standard IAS 29, owing to adverse currency
effects, although the Brazilian real and the Argentinean peso
have partly recovered in recent months.

To stabilize its market shares and earnings, DIA unveiled a wide-
ranging strategic plan on October 30. The company will review its
product offering, strengthen its private label, change its
pricing, modify franchise agreements and cut costs, among other
measures. It will also lower capital expenditures (capex) in 2019
which, together with the cancellation of the dividend, should
support cash flow generation: the rating agency estimates free
cash flow to be around negative EUR75 million in 2019, on a
Moody's-adjusted basis, compared to a forecast of about negative
EUR400 million for 2018. However, Mercadona and Lidl are
investing heavily and so DIA will likely be under pressure to
increase capex in subsequent years. Turning operations around
will take time and will depend on the company's ability to
preserve good relationships with its franchisees and its
suppliers despite financial difficulties.

Moody's thinks that the profit warning and the accounting errors
point to weaknesses in DIA's governance. It has started
addressing these governance issues by changing its management
team, notably its Chief Executive Officer, its chairman of the
board and part of its finance team. However, significant
management changes add to the execution risks associated with the
transformation plan.

RATIONALE FOR THE NEGATIVE OULOOK

The negative outlook reflects Moody's view that DIA's liquidity
could come under significant pressure if it does not find new
sources of financing and reset its covenant in a timely manner.
It also reflects the weaker competitive and earnings profile as
well as the execution risk related to the implementation of the
new strategic plan and the possibility that competition may
increase further in the Spanish market.

WHAT COULD CHANGE THE RATING UP/DOWN

Moody's could lower DIA's ratings if it appeared unable to
refinance its short-term debt maturities, notably the EUR300
million bond (outstanding amount) maturing in July 2019, and to
put in place a long-term capital structure. Failing to restore
adequate covenant headroom could also cause a negative rating
action. Moreover, Moody's could downgrade DIA's ratings if it
appeared unable to gradually stabilize its earnings and improve
its Moody's-adjusted free cash flows.

Although a positive rating action is unlikely for the moment in
light of the downgrade, Moody's could upgrade DIA's ratings if it
restored an adequate liquidity position, with substantial
headroom under its covenants and limited short-term debt
maturities. A positive rating action would also be contingent on
an improvement in Moody's-adjusted EBITDA and free cash flows as
well as a financial policy supportive of higher ratings.

LIST OF AFFECTED RATINGS

Issuer: Distribuidora Internacional de Alimentacion

Downgraded after being on review for downgrade:

LT Corporate Family Rating, Downgraded to B2 from Ba2

Probability of Default Rating, Downgraded to B2-PD from Ba2-PD

Senior Unsecured Medium-Term Note Program, Downgraded to (P)B2
from (P)Ba2

Senior Unsecured Regular Bond/Debenture, Downgraded to B2 from
Ba2

Outlook Actions:

Outlook, Changed To Negative From Rating Under Review

PRINCIPAL METHODOLOGY

The principal methodology used in these ratings was Retail
Industry published in May 2018.

COMPANY PROFILE

Based in Madrid, Spain, DIA is one of the main food discounters
in Europe, with EUR8.6 billion of revenue in 2017. Excluding its
Chinese operations, which it sold in August 2018, the company
operated 7,388 stores as of December 31, 2017. Of those, 4,713
were in Spain, 630 were in Portugal, 1,115 in Brazil and 930 in
Argentina. In 2017, Spain and Portugal accounted for 64% of
revenue and 75% of company-adjusted EBITDA.


===========================
U N I T E D   K I N G D O M
===========================


FOLGATE INSURANCE: A.M. Best Assigns B(Fair) FSR, Outlook Stable
----------------------------------------------------------------
A.M. Best has assigned a Financial Strength Rating (FSR) of B
(Fair) and a Long-Term Issuer Credit Rating (Long-Term ICR) of
"bb+" to Folgate Insurance Company Limited (Folgate) (United
Kingdom). The outlook assigned to these Credit Ratings (ratings)
is stable.

The ratings reflect Folgate's balance sheet strength, which A.M.
Best categorises as adequate, as well as its adequate operating
performance, very limited business profile and appropriate
enterprise risk management.

Folgate was acquired by its parent, Anglo London Limited (ALL),
in 2014, and re-commenced active underwriting in September 2015,
writing quota-share reinsurance for business sourced by an
affiliated company, Anglo Pacific Consultants (London) Limited
(APC). APC is a managing general agent specialising in commercial
lines insurance for small and medium-sized businesses. In 2018,
Folgate received an insurance licence and, as part of its new
business model, has secured a co-insurance agreement with a
Lloyd's syndicate to support its capacity. According to the
agreement, starting in 2019, Folgate will accept 30% of APC's
U.K. risks, with the remainder placed with the syndicate. The
insurer expects gross written premiums of approximately GBP 8
million in 2019.

Folgate's balance sheet strength is underpinned by projected
risk-adjusted capitalisation at the very strong level, as
measured by the Best's Capital Adequacy Ratio (BCAR) as of year-
end 2019. The impact from ALL on balance sheet strength is
assessed as negative, due to its inadequate consolidated BCAR
scores, high financial leverage and limited financial
flexibility. In addition, Folgate's risk-adjusted capitalisation
is exposed to potential volatility in stressed scenarios, due to
its small capital base.

A.M. Best expects the insurer's underwriting portfolio to be
highly concentrated by product and geography, dominated by U.K.
commercial lines insurance. In addition, A.M. Best views
Folgate's position in the competitive U.K. market as vulnerable
and highly dependent on third parties. This is partly mitigated
by APC's underwriting expertise and existing broker
relationships, which are expected to benefit Folgate's business
profile.

Based on the performance of the business underwritten by APC,
A.M. Best expects Folgate's underwriting results to be positive.
Folgate will be managed by APC, whose commissions will make up
most of the insurer's operational expenses. Operating performance
is expected to benefit from modest investment income.


FONTWELL SECURITIES 2016: Fitch Affirms CCCsf Class S Debt Rating
-----------------------------------------------------------------
Fitch Ratings has upgraded the ratings on five classes and
affirmed the remaining 14 classes of Fontwell Securities 2016
Limited as follows:

Class A: affirmed at'AAsf'; Outlook Negative

Class B: affirmed at 'AAsf'; Outlook Negative

Class C: affirmed at 'AAsf'; Outlook Negative

Class D: affirmed at 'AAsf'; Outlook Negative

Class E: affirmed at 'AAsf'; Outlook Negative

Class F: affirmed at 'A+sf'; Outlook Stable

Class G: affirmed at 'A+sf'; Outlook Stable

Class H: affirmed at 'A+sf'; Outlook Stable

Class I: upgraded to 'Asf' from 'BBB+sf'; Outlook Stable

Class J: affirmed at 'BBB+sf'; Outlook Stable

Class K: affirmed at 'BBB+sf'; Outlook Stable

Class L: upgraded to 'BBB+sf' from 'BBBsf'; Outlook Stable

Class M: affirmed at 'BB+sf'; Outlook Stable

Class N: upgraded to 'BB+sf' from 'BBsf'; Outlook Stable

Class O: upgraded to 'BB+sf' from 'BBsf'; Outlook Stable

Class P: affirmed at 'B+sf'; Outlook Stable

Class Q: affirmed at 'B+sf'; Outlook Stable

Class R: upgraded to 'Bsf' from 'B-sf'; Outlook Stable

Class S: affirmed at 'CCCsf';

Class T: unrated

The transaction is a granular synthetic securitisation of
partially funded credit default swaps (CDS) referencing a static
portfolio of secured loans granted to UK borrowers in the farming
and agriculture sector. The loans were originated by AMC plc
(AMC), a fully owned subsidiary of Lloyds Bank plc (Lloyds,
A+/Stable/F1).

The ratings of the notes address the likelihood of a claim being
made by the protection buyer under the CDS by the end of the six-
year protection period, in accordance with the documentation.

KEY RATING DRIVERS

Increased Credit Enhancement

The upgrade of the notes reflects increased credit enhancement
due to the transaction's deleveraging since its last rating
action in December 2017. The class A notes have partially
amortised by GBP115.2 million since the last rating action,
leading to a moderate increase in credit enhancement available
for all the notes.

Low Default Risk:

The transaction has performed better than Fitch's expectations
with 90+ days delinquencies of around 0.25%, which is lower than
the expected annual average probability of default (PD) for the
SME sector in the UK over the next five years. However, Fitch
continues to assign a one-year average PD (based on 90 days past
due) of 2% to all borrowers in the portfolio, on account of risks
associated with Brexit.

Limited Collateral Dilution Risk

The eligibility criteria and the originator's policies set the
maximum loan-to-value (LTV) at 60%, calculated on a borrower
basis. However, available mortgage collateral secures all AMC
exposure including debt outside of the transaction. Any
recoveries will be shared pro rata across the different AMC debts
of a borrower. While the current LTV in the portfolio is 30.92%,
any additional lending could reduce the collateral share for the
securitised exposures.

Fitch has stressed the LTV to 50% for loans with LTV under 50%.
The vast majority of available collateral is over agricultural
land, which has seen an increase in value over the last 10 years
of approximately 200%. In the recovery analysis, Fitch has
applied its commercial property haircuts, which at the 'AA'
level, are 75% and would reverse most of the increase experienced
over the last 10 years.

Limited Obligor Concentration

The portfolio is diverse with a total of 8,317 loans. The largest
obligor and top 10 contribute to around 0.27% and 2.74% of the
total portfolio balance.

Single Industry Exposure

All the borrowers in the reference portfolio are exposed to the
UK farming and agriculture sector. Accordingly, Fitch continues
to apply a bespoke correlation of 10%.

Direct Subsidy Dependency

The farming and agricultural sector continues to be highly
dependent on direct subsidies, currently provided by the European
Union; these would be replaced by UK subsidiaries after Brexit.
Fitch places the subsidy support threshold (SST) at the Long-Term
Issuer Default Rating of the UK (AA/Outlook Negative). The SST
constrains the maximum achievable rating in the capital structure
at 'AAsf'.

RATING SENSITIVITIES

Increasing the default probabilities assigned to the underlying
obligors by 25% could result in a downgrade of up to two notches
for rated classes.

Decreasing the recovery rates assigned to the underlying obligors
by 25% could result in a downgrade of up to seven notches for the
rated classes.

USE OF THIRD-PARTY DUE DILIGENCE PURSUANT TO RULE 17G-10

Form ABS Due Diligence-15E was not provided to, or reviewed by,
Fitch in relation to this rating action.

DATA ADEQUACY

Fitch has checked the consistency and plausibility of the
information it has received about the performance of the asset
pool and the transaction. There were no findings that affected
the rating analysis. Fitch has not reviewed the results of any
third-party assessment of the asset portfolio information or
conducted a review of origination files as part of its ongoing
monitoring.

Prior to the transaction closing, Fitch reviewed the results of a
third-party assessment conducted on the asset portfolio
information and concluded that there were no findings that
affected the rating analysis.

Prior to the transaction closing, Fitch conducted a review of a
small targeted sample of the originator's origination files and
found the information contained in the reviewed files to be
adequately consistent with the originator's policies and
practices and the other information provided to the agency about
the asset portfolio.

Overall and together with the assumptions referred, Fitch's
assessment of the information relied upon for the agency's rating
analysis according to its applicable rating methodologies
indicates that it is adequately reliable.


INTERSERVE PLC: Expects Higher Than Expected Debt This Year
-----------------------------------------------------------
Gill Plimmer and Camilla Hodgson at The Financial Times report
that troubled outsourcer Interserve said on Nov. 23 that its
debts would be higher than expected this year, adding to concerns
over the company's financial health.

The group, which provides a range of services for schools,
hospitals and government departments, said year-end debt would
rise from the GBP575 million-GBP600 million previously announced
to between GBP625 million-GBP650 million, the FT relates.

According to the FT, although the company attempted to reassure
the market that its troublesome energy-to-waste incinerator
projects had been completed and were ready for handover, it
acknowledged that delays in the third quarter had resulted in
penalties that would lower cash inflows on the projects to GBP15
million from an earlier estimate of GBP32 million.

Earlier this month, shares in Interserve plummeted to their
lowest point since 1984 on reports it was facing a cash crisis
and was close to bankruptcy, the FT recounts.

It has revenues of GBP3.25 billion but is valued by the stock
market at just GBP75 million and is already under close watch by
the British government in case of collapse, the FT discloses.

Interserve employs 80,000 people worldwide -- 25,000 in the UK --
in jobs that range from cleaning the London Underground to
maintaining army bases and building a shopping centre in Dubai.


JOHNSON PRESS: Moody's Lowers CFR to Ca, Outlook Stable
-------------------------------------------------------
Moody's Investors Service has downgraded the ratings of UK local
and regional media company Johnston Press plc, including the
Corporate Family Rating to Ca from Caa3, the Probability of
Default Rating to D-PD from Caa3-PD and the rating on the
company's GBP220 million outstanding senior secured notes due
2019 issued by its subsidiary Johnston Press Bond Plc to Ca from
Caa3. The outlook on the ratings is stable.

The downgrade follows the announcement on November 16th that the
company has entered administration.

Shortly following these rating actions, Moody's will withdraw all
of Johnston Press's ratings, consistent with Moody's practice for
companies operating under the purview of the bankruptcy courts
wherein information flow typically becomes much more limited.

RATINGS RATIONALE

The rating action follows the company's announcement on November
16, 2018 that it had filed for administration, which is
considered a default by Moody's. Johnston Press's businesses and
assets, but not its pension fund, have been sold to a new entity
created by its noteholders. Following completion of the sale,
both Johnston Press plc and Johnson Press Bond Plc are
essentially shell companies with no operating assets.

The Ca CFR and Ca rating on the company's senior secured notes
incorporate Moody's final recovery assumptions.

RATIONALE FOR STABLE OUTLOOK

The stable outlook reflects the fact that Johnston Press is
likely to remain in administration for some time before the
Administrator winds up group companies.

LIST OF AFFECTED RATINGS

Downgrades:

Issuer: Johnston Press Bond Plc

BACKED Senior Secured Regular Bond/Debenture, Downgraded to Ca
from Caa3

Issuer: Johnston Press plc

Probability of Default Rating, Downgraded to D-PD from Caa3-PD

Corporate Family Rating, Downgraded to Ca from Caa3

Outlook Actions:

Issuer: Johnston Press Bond Plc

Outlook, Changed To Stable From Negative

Issuer: Johnston Press plc

Outlook, Changed To Stable From Negative

PRINCIPAL METHODOLOGY

The principal methodology used in these ratings was Media
Industry published in June 2017.

COMPANY PROFILE

Johnston Press plc was a leading UK multimedia company that
published daily newspapers, including The Scotsman, The Yorkshire
Post and The News (Portsmouth), paid for weeklies, free
newspapers and magazines. In 2017, Johnston Press reported
underlying revenue of GBP201.6 million and underlying EBITDA of
GBP40.1 million.


NEW LOOK: Moody's Lowers CFR to Ca, Outlook Negative
----------------------------------------------------
Moody's Investors Service has downgraded the Corporate Family
Rating of New Look Retail Group Limited to Ca from Caa2 and its
probability of default rating to Ca-PD from Caa2-PD.
Concurrently, Moody's has downgraded the rating of the GBP700
million and the EUR415 million senior secured notes due in July
2022 issued by New Look Secured Issuer plc to Caa3 from Caa1 and
the rating of the GBP176 million outstanding senior unsecured
notes due in July 2023 issued by New Look Senior Issuer plc to C
from Ca. The outlook on all ratings remains negative.

"Our downgrade reflects New Look's inadequate liquidity profile
and the unlikely financial support from its owner, Brait SE,
which will lead to a restructuring of the company's unsustainable
capital structure," says Victor Garcia Capdevila, Moody's lead
analyst for New Look. "Although the turnaround strategic plan put
in place by the new senior management team is improving the
operating performance, EBITDA will not grow rapidly enough to
refinance the current capital structure on reasonable terms and
without significant financial losses for bondholders," adds Mr.
Garcia.

RATINGS RATIONALE

New Look's internal cash flow generation and its availability
under external liquidity and trade and import facilities are not
sufficient to service debts and fund working capital and capex
requirements.

Cash and cash equivalents as of September 22, 2018 amounted to
GBP71.3 million, out of which c.GBP12 million is restricted cash,
the GBP100 million revolving credit facility is fully utilized,
while the GBP15 million overdraft facility is still available.
This translates into a balance of available cash and liquidity
facilities of GBP74.3 million as of Q2 2018 compared to GBP196.4
million a year earlier.

The company has GBP85 million of trade and import facilities to
fund working capital needs and advance payments to suppliers. The
availability under this facility as of Q2 2018 was GBP7.5
million. Overall, New Look's total unrestricted cash, liquidity
and operating facilities totaled GBP81.8 million as of Q2 2018,
significantly below the GBP230.5 million available in Q2 2017.

Its base case scenario assumes that the company will generate
funds from operations of around GBP6 million in the second half
of fiscal year 2019 and will have a negative change in working
capital of around GBP40 million. Coupled with a committed capital
spending of GBP10 million for the rest of 2019 and cash costs of
GBP8 million to exit China, this translates into a forecast cash
balance of around GBP20 million at the end of fiscal year 2019,
which is materially below its assumption of a cash need of at
least GBP40 million to run the business through the seasonal cash
peaks and troughs. In addition, the GBP15 million overdraft
facility and the GBP85 million trade and import facilities mature
on January 31, 2019. Although these facilities have been extended
for three months, future extensions are not committed and are at
the full discretion of banks.

The company's tight liquidity profile is also likely to have a
negative effect on its future operating performance due to the
lack of necessary investments in IT, digital platforms, marketing
and advertisement, store maintenance and refurbishments. It is
also hindering the ability of the new management team to maximize
the benefits of the turnaround plan.

Brait SE, the owner of New Look, is unlikely to provide financial
support to the company. The investment company has written off
100% of its investment in New Look and in the past financial
support to the company was in the form of a factoring facility
for New Look's receivables at a cost of Libor+2.0%.

Moody's adjusted gross leverage at the time of the acquisition of
New Look by Brait SE was 5.5x and it was expected that the
company would generate a run-rate reported EBITDA of around
GBP230 million. For the last 12 months to September 2018 Moody's
adjusted gross leverage and reported EBITDA were 13.2x and
negative GBP35 million respectively. The rating agency estimates
that reported EBITDA will be around GBP100 million in fiscal year
2019.

The current debt levels are unsustainable. 80% of EBITDA in
fiscal 2019 will be absorbed by interest payments, and a
liquidity event in the next few months is likely to trigger a
restructuring of the capital structure. Moody's considers that in
such a scenario recovery rates for senior bondholders are likely
to be between 35-65%. This is consistent with a Ca CFR.

RATIONALE FOR THE NEGATIVE OUTLOOK

The negative outlook reflects the possibility of recovering rates
being lower than 35%.

WHAT COULD CHANGE THE RATING UP/DOWN

Upward pressure on the rating is unlikely in the short term but
could arise if liquidity pressures are resolved and the company
shows signs of a sustainable recovery in profitability such that
a refinancing of the current capital structure on reasonable
terms is achievable.

Downward pressure on the rating could arise if expected recovery
rates for financial creditors are less than 35%.

The principal methodology used in these ratings was Retail
Industry published in May 2018.


PHONES4U: Taps Insolvency Expert to Assess Damages Claims
---------------------------------------------------------
Christopher Williams at The Telegraph reports that one of the
country's top insolvency experts has been called in to the
administration of Phones 4u to assess whether to launch a damages
claims worth hundreds of millions of pounds against mobile
operators over their alleged role in the collapse of the
retailer.

Paul Copley, who has worked on high-profile insolvencies and
complex restructuring projects including Lehman Brothers,
Kaupthing Bank, Cooperative Bank and Steinhoff International, was
appointed on Nov. 23, The Telegraph relates.

According to The Telegraph, sources said he will lead an attempt
to recover a sum in the "upper hundreds of millions" from mobile
operators over claims their unlawfully colluded to cut Phones 4u
out of the market.


VICTORIA PLC: Fitch Withdraws BB-(EXP) LT Issuer Default Rating
---------------------------------------------------------------
Fitch Ratings has withdrawn UK-based flooring products
manufacturer Victoria PLC's 'BB-(EXP)' expected Long-Term Issuer
Default Rating (IDR) with Stable Outlook. Fitch has also
withdrawn the expected instrument rating of 'BB(EXP)' assigned to
the group's proposed senior secured notes.

KEY RATING DRIVERS

Fitch is withdrawing the expected ratings assigned to Victoria,
as the group does not intend to proceed with the proposed bond
issuance. The expected ratings were assigned on October 30, 2018.

RATING SENSITIVITIES

No sensitivities apply, as the ratings were withdrawn.


* UK: 1,267 Retail Stores Earmarked for Closure Since January
-------------------------------------------------------------
Josh Wilson and Patrick Scott at The Telegraph report that
Britain's high street has endured a terrible year so far with
several big companies entering administration and others seeking
to slash the size of their store estates.

A growing list of retailers have announced major cutbacks and
shop closures since the start of the year -- most recently
Debenhams has announced plans to close 50 of its under-performing
stores putting 4,000 jobs at risk, The Telegraph discloses.

According to the Telegraph's store closure tracker, which tracks
closures from major retailers, an estimated 1,267 shops have been
closed or earmarked for closure since January -- potentially
putting 25,159 jobs at risk.



                            *********

Monday's edition of the TCR delivers a list of indicative prices
for bond issues that reportedly trade well below par.  Prices are
obtained by TCR editors from a variety of outside sources during
the prior week we think are reliable.  Those sources may not,
however, be complete or accurate.  The Monday Bond Pricing table
is compiled on the Friday prior to publication.  Prices reported
are not intended to reflect actual trades.  Prices for actual
trades are probably different.  Our objective is to share
information, not make markets in publicly traded securities.
Nothing in the TCR constitutes an offer or solicitation to buy or
sell any security of any kind.  It is likely that some entity
affiliated with a TCR editor holds some position in the issuers'
public debt and equity securities about which we report.

Each Tuesday edition of the TCR contains a list of companies with
insolvent balance sheets whose shares trade higher than US$3 per
share in public markets.  At first glance, this list may look
like the definitive compilation of stocks that are ideal to sell
short.  Don't be fooled.  Assets, for example, reported at
historical cost net of depreciation may understate the true value
of a firm's assets.  A company may establish reserves on its
balance sheet for liabilities that may never materialize.  The
prices at which equity securities trade in public market are
determined by more than a balance sheet solvency test.

Each Friday's edition of the TCR includes a review about a book
of interest to troubled company professionals.  All titles are
available at your local bookstore or through Amazon.com.  Go to
http://www.bankrupt.com/booksto order any title today.


                            *********


S U B S C R I P T I O N   I N F O R M A T I O N

Troubled Company Reporter-Europe is a daily newsletter co-
published by Bankruptcy Creditors' Service, Inc., Fairless Hills,
Pennsylvania, USA, and Beard Group, Inc., Washington, D.C., USA.
Marites O. Claro, Rousel Elaine T. Fernandez, Joy A. Agravante,
Julie Anne L. Toledo, Ivy B. Magdadaro, and Peter A. Chapman,
Editors.

Copyright 2018.  All rights reserved.  ISSN 1529-2754.

This material is copyrighted and any commercial use, resale or
publication in any form (including e-mail forwarding, electronic
re-mailing and photocopying) is strictly prohibited without prior
written permission of the publishers.

Information contained herein is obtained from sources believed to
be reliable, but is not guaranteed.

The TCR Europe subscription rate is US$775 per half-year,
delivered via e-mail.  Additional e-mail subscriptions for
members of the same firm for the term of the initial subscription
or balance thereof are US$25 each.  For subscription information,
contact Peter Chapman at 215-945-7000.


                 * * * End of Transmission * * *